In May, 2000, the House of Commons Standing Committee on Environment and Sustainable Development released a report entitled, “Pesticides: making the right choice for the protection of health and the environment.” The report is very negative on the use of pesticides, and is based on hearings which were heavily weighted with presentations from organizations known for their anti-pesticide views. The report can be found at: http://www.parl.gc.ca/InfoComDoc/36/2/ENVI/Studies/Reports/envi01-e.html . Members of the Standing Committee on Environment and Sustainable Development are listed at: http://www.parl.gc.ca/36/1/parlbus/commbus/house/CommitteeMember.asp?Language=E&CommitteeID=79 .

A copy of the following letter was sent by OCPA to each member of the House of Commons Standing Committee on Environment and Sustainbable Development, with carbon copies sent to other Members of Parliament:

Dear Sir/Ma'am:

In cooperation with several other farm environmental leaders in Ontario I have reviewed the report of the Standing Committee entitled, “Pesticides: making the right choice for the protection of health and the environment.”. The report contains several statements, implications, conclusions, and recommendations which are somewhat misleading and potentially detrimental to the well-being of Canadians and the natural environment. More specific comments follow:

1. The entire report seems very biased against pesticide usage, emphasizing risks while largely ignoring public benefits. The bias is evident right from the chair’s prefatory statement where he equates pesticide usage with tobacco consumption, ignoring the fact that smoking provides no societal benefit and is a dominant cause of human cancer, while pesticides provide major benefits with linkages to cancer being largely conjectural. A more obvious comparison would have been with antibiotic (i.e., “anti-life”) products which differ from pesticides only in the fact that the former control internal pathogens/pests while the latter address external pest problems.

2. Adding to this concern is the distinct imbalance in the selection of witnesses, including many anti-pesticide activist groups, while ignoring important players such as the Canadian Cancer Society, the Canadian Network of Toxicology Centres, the Consumers’ Association of Canada, the Canadian Medical Association, and most Canadian university researchers with specific expertise on pesticide risk and management issues. As one example, the only witness invited from the University of Guelph, known for its research and expertise in pesticide usage in both turf management and food production, was an economist known for his strong pro-organic advocacy.

3. Finally, the report ignores several key and internationally recognized studies which have been completed in recent years on pesticides and health/environmental risks. These include the major, peer-reviewed study, “Report of a panel on the relationship between public exposure to pesticides and cancer,”Ad Hoc Panel on Pesticides 1997. Another example is series of research reports on homeowner exposure to pesticides used on turf published by Harris, Solomon and Stephenson in 1992. Also ignored are a series of widely acclaimed, peer-reviewed articles and reviews published by the internationally recognized US pesticide and cancer-risk researcher, Dr. Bruce Ames (also founder of the “Ames” test used routinely to test for chemical mutagenicity). It’s curious to see the committee give such attention to the personal opinions of one American, Dr. Theo Colborn, employed by an environmental group, whose writings have not generally been peer-reviewed by health and scientists, while ignoring the much more professionally respected research work of individuals such as Dr. Ames.

4. The report emphasizes risks associated with pesticide usage, but ignores risks with the alternatives. For example, essentially all gasoline-powered lawn mowers (no catalytic converters) are notorious polluters. The US Environmental Protection Agency says “a lawnmower pollutes as much in one hour as does driving an automobile for 350 miles.” The Californian South Coast Air Quality Management District says “ a conventional lawn mower pollutes as much in an hour as 40 late model cars.” If reduced pesticide usage means an additional lawn cutting per year, how does the environment benefit?

   Even worse are two-cycle-engine string trimmers such as that shown in a recent national newspaper photo displaying a photograph of a Halifax city employee using a string weeder as an alternative to pesticides for pest control. According to the Michigan State University School of Engineering 25 percent of fuel can be exhausted from these engines, and up to 50% when engines are untuned. The Air Resources Board of the California EPA says using a chain saw (similar two-cycle engine) “for two hours produces the same amount of smog-forming emissions as driving ten 1995 cars about 250 miles each.” The string weeder, with its gasoline-powered two-cycle engine, is a powerful source of carcinogenic and ozone-causing emissions. That string weeder photographed in Halifax may have emitted greater quantities of known carcinogens in an hour of usage, than all of the herbicides used on city lawns for weed control in a year. The City of Seattle on its web site on “Alternative pest control practices” recommends the use of string trimmers “where environmental trade-offs of air and noise pollution do not outweigh benefits of pesticide reduction.” By contrast, references to such environmental trade-offs are notably absent from the report of the standing committee.

5. The report implies that most homeowner exposure to pesticides comes from lawn spraying, but this is highly unlikely. In fact, homes themselves contain many pesticides — disinfectants, insect repellents, ant traps, swimming pool treatments, and many more. And the level of human exposure with many of these is much higher than with the typical once-per-year applications of lawn herbicides. Indeed, a statement that two-thirds of Canadian homeowners use pesticides (Section 4.7) is almost certainly low; the true figure is likely closer to 100 percent. The report does note that more than more than 7000 pesticide products are registered in Canada (Section 3.5). My industry contacts suggest that only a minority of these are used for food production and lawn care; the rest are used for other consumer and industrial purposes.

6. While the report dwells on the need for special attention to the need of children, my understanding is that this is already recognized in Canadian pesticide regulatory procedures and by the World Health Organization — particularly in “maximum residue limits” which apply to pesticide usage in food production. Unfortunately, the report all but ignores this reality.

7. The report condemns the fact that the Government of Canada relies on company-supplied data to make judgments on the safety of pesticide products. The same criticism has been made elsewhere about approvals of new ?novel’ foods and agricultural crops by Health Canada. But the report does not note that the same process applies for a vast number of other health and consumer products — like new pharmaceuticals and cosmetics — and it’s the same in all other OECD countries. The misleading impression is given that this is a “flaw” unique to Canadian pesticide regulation.

   Some would suggest that farmers should not care about dandelions and other weeds in lawns (though farmers must control dandelions in crop fields where they can cause serious yield losses). But many of us do get pleasure in attractive lawns, just as do millions of other Canadians. It is somewhat disconcerting to see the standing committee dismiss such aesthetic considerations as having no human or health benefits. If the roses which add some beauty around our house are destroyed by diseases and we want to apply pesticides (this includes organic pesticides) to protect the flowers, is this without value? Should human cosmetics be banned because they cannot be proven to be 100% safe, and their approval is based on company-supplied data, even though they help people feel good about their appearance? Or should oil-based pigments used in paintings be banned because they may contain potentially hazardous compounds, even though they provide aesthetic value to those who hang these works on the walls of their homes and offices — or art galleries in Ottawa? Aesthetics do have health benefits, conclusions of the committee’s report notwithstanding, and should not be so readily dismissed.

8. This is not to suggest that special attention should not be paid, at the neighbourhood level, to those who have proven sensitivity to chemical ingredients. However, a recent critical review of the issue of “multiple chemical sensitivity” has shown that most of the reported “cases” are more likely related to psychological causes or fraudulent activity of so-called specialists in “ecological medicine” (Barrett and Gots, 1999). There are likely more Canadians who suffer from allergies linked to fungus, insect and mite proteins, bee stings, lawn cuttings, gasoline-engine emissions, and weed pollen. The role of pesticides in preventing these exposures must be viewed in this context.

9. From a specific agricultural perspective, the report contains information and conclusions which seem implausible and/or inconsistent. One is the statement that atrazine, a herbicide used almost exclusively for corn production, is a dominant soil water contaminant in Saskatchewan, a province where almost no corn is grown. Another is the report’s emphasis on integrated pest management, technology which depends on a range of alternatives for pest control, while recommending that pesticide alternatives be eliminated in favour of individual techniques considered to be more environmentally benign. History has proven that dependence on any single technology is a recipe for the rapid development of genetic resistance within pest species.

10. It is also disappointing that no mention is made of the success of Ontario agriculture in reducing agricultural pesticide usage by 40.7% between 1983 and 1998, while improving provincial agri-food output by a substantial percentage. An analysis by the University of Guelph shows that the reduction in usage has been accompanied by a corresponding decline in overall potential toxicity (Gallivan et al, 1998).

    An extensive survey of municipal drinking water from groundwater wells across Ontario, conducted by the University of Waterloo and commissioned by the Sierra Club of Canada, found only two of 79 with any traces of pesticides, and the levels in both cases were well below safe drinking water tolerances (Harman and Blundell, 1999). A 1991 and 1992 survey of pesticide levels in Ontario rural wells found only two sites in fall/winter and one in summer, out of 1300, which exceeded maximum acceptable concentrations — a finding which is inconsistent with the “spin” contained in the committee report. It is interesting that the standing committee has overlooked the fact that the same survey found that 31% percent of wells contained coliform bacteria, a finding of much greater health significance (Ontario Farm Groundwater Survey, Winter. 1991/92 and Summer 1992).

11. The committee’s statement that incidence of non-Hodgkin’s lymphoma (NHL) is linked to farm pesticide usage seems more conjecture than fact. For example, a major study in Saskatchewan found lower levels of NHL for farmers who sprayed the largest acreages of crops in 1970 (over 1000 acres) than for those who sprayed smaller acreages (Wigle et al., 1990). Similar inconsistencies exist in data published by other researchers.

12. The news release which accompanied the release of the committee report states, incorrectly, that organic farming means reduced soil erosion, and the report itself contains similar dubious conclusions. A check of references shows that the source is generally testimonials from pro-organic agriculture supporters rather than research data. Organic agriculture generally means frequent soil tillage as an alternative to pesticides for weed control, and tillage is the number one cause of soil erosion.

13. The report also fails to note that organic agriculture does involve the use of registered pesticides, many of which can be very toxic if misused (e.g., copper sulphate to humans, and rotenone to fish), just as is the case with other pesticides. In addition, the report ignores any of the other potential environmental and health risks with organic technology. In addition to increased usage of tillage and fossil fuel for weed control (some organic producers even use propane burners for control of field insects), these risks include the direct use of manure for fertilizing vegetable crops. That manure can contain living E. coli and other potentially hazardous bacteria, even after composting. Organic agriculture generally means lower crop yields (more land to grow the same amount of food) and higher food prices. This may be a strategy for an elite group of more wealthy Canadians, but is it a rational approach for a hungry world, where continuing large percentages of available food are destroyed by pests before they can be eaten by humans?

14. The report makes frequent usage of the term “precautionary principle” but uses it in only a one-way sense. “Precaution,” in terms of the committee’s report, seems to mean that pesticide usage should be eliminated because of its potential risks. However, there is no consideration of the risks of alternatives. Should society not err on the side of lower-cost food, especially of vital fruits and vegetables needed for healthy children? If pesticide usage means increased weed pollen drift or increased use of lawnmowers and string weeders, does this mean erring on the side of safety? Or is a good precaution to eliminate disinfectants, mosquito repellents, swimming pool treatments, etc., from Canadian homes, hospitals, recreation centres, etc., for health and environmental considerations? In no place does the report recognize that use of a pesticide might represent implementation of the so-called “precautionary principle.”

    The precautionary principle is usually applied in situations where the risk of harm is judged to be great and scientific information about the issue is lacking or minimal. This is certainly not the case for pesticides. Pesticides are examples of a class of chemical substances for which there is a large amount of data on possible human and ecological effects. These data are required by law in Canada and other countries for use in registration and re-registration processes. For this class, use of the precautionary principle is clearly inappropriate.

15. The committee’s condemnation of the placing of all pesticide regulatory functions within the Pesticide Management Regulatory Agency is diametrically opposite to the rationale which led to the creation of this agency by the present Government of Canada in the mid 1990s. This action, in turn, stemmed from recommendations of a major review completed by the Pesticide Registration Review Team (PRRT) in 1990. The PRRT recommended a more coordinated approach versus the status quo of that time, where pesticide regulatory responsibilities were scattered “piecemeal” among several departments. It make good sense to have one agency review all facets of pesticide registration, versus a confrontational approach between departments/agencies which is the likely alternative. It is unfortunate that the report of the PRRT, and the rationale inherent therein, were not more seriously considered in the committee’s deliberations of 2000. The PRRT report is the result of an intense two-year review, involving environmentalists, consumer and health reps, farmers, industry personnel, and government representatives.

16. The committee’s recommendation that the Economic Management Advisory Committee (EMAC) of PMRA be disbanded seems somewhat high-handed, especially given the fact that the parliamentary committee did not even meet with the EMAC. In fact, it is widely recognized that the other PMRA advisory committee, the Pest Management Advisory Council, has a strong imbalance in favour of those opposed to pesticide usage. There are few farmers, industry and consumer representatives in contrast to the large numbers from special interest groups. The sole representative from the University of Guelph, for example, is an organic advocate, rather than someone with any known expertise in pesticide usage, toxicology, environmental biology, or risk management. It is recognized, however, that this imbalance is partially offset by the existence of the EMAC. It would be irresponsible to eliminate the latter, without a complete remake of the advisory council as well, to provide balance.

Because of the bias and obvious limitations of this report, it is important that the Government of Canada’s consultative process be more complete, objective, and balanced, as it decides on the nature of pesticide regulatory needs for future years.

Sincerely,

Terry Daynard
Executive Vice-President, Ontario Corn Producers’ Association
(Also, substitute representative on the former Pesticide Registration Review Team)

References cited:

Publications

Ad Hoc Panel on Pesticides. 1997. Report of a panel on the relationship between public exposure to pesticides and cancer. Cancer 80:2019-2033.

Ames, Bruce N. 1989. What are the major carcinogens in the etiology of human cancer? Pages 237-247 in Important Advances in Oncology, J.B. Lippincott Co., Philadelphia.

Ames, B. N., and L.S. Gold. 1997. Environmental pollution, pesticides, and the prevention of Cancer: Misconceptions. Federation of American Societies for Experimental Biology Journal 11: 1041-1052.

Barrett S., and R.E.Gots. 1999. Chemical Sensitivity: The Truth About Environmental Illness. Prometheus Books, Amherst, NY. 212 p.

Gallivan, G.L., G.A. Surgeoner, and J. Kovach. 1998. An analysis of pesticide risk reduction on crops in Ontario using the Environmental Impact Quotient. Department of Environmental Biology, University of Guelph.

Harman, J., and G. Blundell. 1999. A survey of the quality of municipal drinking water from groundwater sources in Ontario. University of Waterloo and Sierra Club of Canada.

Harris S.A., and K.R. Solomon.1992a. Human exposure to 2,4-D following controlled activities on recently sprayed turf. Journal of Environmental Science and Health B27:9-22.

Harris S.A., and K.R. Solomon.1992b. Percutaneous penetration of 2,4-dichlorophenoxyacetic acid and 2,4-D dimethylamine salt in human volunteers. Journal of Toxicology and Environmental Health 36:233-240.

Harris S.A., K.R.Solomon, and G.R.Stephenson. 1992. Exposure of homeowners and bystanders to 2,4-dichlorophenoxyacetic acid (2,4-D). Journal of Environmental Science and Health B27:23-38.

Rudolph, D., and M. Goss. 1992. Ontario Farm Groundwater Quality Survey. Winter 1991/92.

Rudolph, D., and M. Goss. 1993. Ontario Farm Groundwater Quality Survey. Summer 1992.

Wigle, D.T., R.M. Semenciew, K. Wilkins, D. Riedel, L. Ritter, H.I. Morrison, and Y. Mao. 1990. Mortality study of Canadian male farm operators: non-Hodgkin’s lymphoma mortality and agricultural practices in Saskatchewan. Journal of the National Cancer Institute 82: 575-582.

Web sites

Alternative Pest Control Practices for City of Seattle Grounds Managers, http://www.ci.seattle.wa.us/environment/pesticides.htm
Dr. Bruce Ames’ home page, http://www.bruceames.org
California Environmental Protection Agency, Air Resources Board, www.arb.ca.gov/msprog/offroad/sm_en_fs.pdf
California South Coast Air Quality Management District, www.aqmd.gov/monthly/garden.html
Small-Engine Emissions Research, School of Engineering, Michigan State University, http://www.egr.msu.edu/erl/emiss/emiss.htm
US Environmental Protection Agency, www.epa.gov